Conflicts of Interest policy

Crofun bvba Conflicts of Interest policy

Overview of the Crofun BVBA’s Conflicts of Interest policy (“Crofun”) in the context of its activities as an alternative funding platform as regulated by the Law of 18 December 2016 governing the recognition and delimitation of crowdfunding and laying down various provisions relating to finance (the “Law”).

1. Why does Crofun have a policy relating to conflicts of interest?

Crofun is committed to acting honestly, fairly and professionally in the interests of the project providers and the investors (the “Clients”). Within this framework, Crofun takes all reasonable measures to prevent conflicts of interest between itself and the Clients on the one hand and among Clients on the other.

In accordance with the Law, as an alternative funding platform Crofun is required to set its Conflicts of Interest policy down in writing and implement and maintain this policy. This document provides a summary of the key points of the Conflicts of Interest policy; if the Client requires more information he can contact Crofun at any time by e-mail at service@crofun.com.

2. What is a conflict of interests?

A conflict of interests is a conflict that arises when there are two conflicting interests, which could possibly have adverse implications for the interests of the investor and/or the project provider. Conflicts may arise between the interests of:

Crofun, including its senior managers and employees, and the investor;

Crofun, including its senior managers and employees, and the project provider;

the investors;

the project providers;

various senior managers, employees or authorised representatives of Crofun or companies belonging to the same group.

3. What are potential conflicts of interest?

As a first step Crofun has identified a number of potential conflicts of interest, in order to be able to take the necessary steps to prevent these conflicts or, if that proves impossible, to manage them properly. The potential conflicts of interest are recorded by Crofun in a central list that is regularly reviewed and updated where necessary. The Client can request this list free of charge at service@crofun.com.

The following incomplete list gives a number of examples of where a potential conflict of interest can arise:

Crofun may make a financial gain at the expense of the Client;

Crofun may make a financial gain by allowing the interests of certain Clients to take precedence over the interests of other Clients;

Crofun may make a financial gain by referring Clients to external parties with which Crofun has cooperation agreements.

4. What measures does Crofun take to prevent conflicts of interest?

Crofun has taken the following measures to prevent conflicts of interest:

shareholders, managers or family members of shareholders and managers cannot act as investors or project providers;

if a possible conflict of interests is identified, Crofun’s two managers will take a joint decision regarding the transaction in question and attempt to mitigate the potential conflict of interests. If this proves to be impossible, the transaction will not go through;

the managers shall discuss the current procedures on a regular basis, and at least once a year, and where necessary define additional procedures.

5. What measures does Crofun take to manage conflicts of interest

If it is not possible to prevent a potential conflict of interests, Crofun will take measures to manage the conflict so that the interests of the Client are not harmed. If the measures taken are not sufficient to ensure that the interests of the Client will not be harmed, Crofun will notify the Client of the nature and cause of the conflict of interests. The Client can then decide whether he wants to (continue to) use the services offered by Crofun.

6. What fees does CroFun receive?

Crofun receives fees and commissions from project providers in return for its services, as stipulated in Article 14 of the General Terms and Conditions:

to be able to offer a project through Crofun.com, the project provider pays Crofun a one-off advertising fee of EUR 250 incl. VAT, before the project is placed on Crofun.com;

at the end of the subscription period the project provider pays Crofun an additional success fee of 4% of the funding incl. VAT. This success fee is not charged if the minimum funding as specified in Article 12.4 of the General Terms and Conditions is not achieved;

Except for the one-off advertising fee, payments in connection with the use of Crofun.com are made via the Client’s E-wallet as stipulated in Article 17 of the General Terms and Conditions. For the use of this E-wallet and the associated transactions, the project provider pays Crofun a standard fee of 2.5% of the funding received + EUR 0.25 per individual transaction.

7. Where can I find more information?

The Client can obtain more information on the content and implementation of the Conflicts of Interest policy on written request via service@crofun.com.